NOTE DRAFT LONDON PLAN (DECEMBER 2017) COMMENTS BY QUOD ON BEHALF OF THE BRENT CROSS CRICKLEWOOD DEVELOPMENT PARTNERS – MARCH 2018 1 Introduction and Background 1.1 These representations are made on behalf of our client, the Brent Cross Cricklewood (“BXC”) Development Partners (“DPs”). The BXC DPs are a joint venture between two of the UK’s most successful development and property investment companies – Hammerson UK Properties Plc and Aberdeen Standard Investments Ltd. 1.2 Planning Permission (Ref No C/17559/08) for the comprehensive redevelopment of the BXC Regeneration Area was granted in October 2010, and following this, a Section 73 permission (Ref No F/04687/13) was granted by the Council in July 2014. 1.3 The BXC regeneration scheme will realise the Mayor’s long-term aspirations for this key strategic Opportunity Area. The development will bring some 27,000 jobs, 7,500 new homes, a new town centre, a new commercial district and a new high street together with parkland and open space. The plans will also deliver substantial investment into transport and community facilities, including new schools, health facilities, public transport interchanges, bridges and road junctions. 1.4 Since the 2014 Permission was secured, significant progress has been made toward the delivery of the BXC Development. In respect of the development north of the A406 and associated infrastructure, the DPs have obtained approval for the detailed design for both Phase 1A (North) and Phase 1B (North) and are preparing for the discharge of pre-commencement conditions. In addition, in December 2017, the Secretary of State approved the Compulsory Purchase Orders (“CPO”s) for parts of both the northern and the southern areas of the development. 1.5 The DPs have been working with the London Borough of Barnet and the Greater London Authority to deliver a scheme which will provide the Borough with the regeneration that it urgently requires. As recognised in Barnet’s local policy, seeking the regeneration of BXC is critical not only to the future success of the local area but also to North London. It is therefore important that emerging policy does not fetter the ability to deliver the comprehensive redevelopment of BXC and constrain the wider economic benefit to the local area and beyond. 1.6 Our client’s representations to the Draft London Plan are made in this context and are set out below on a chapter by chapter basis. 2 Chapter 1 – Planning London’s Future (Good Growth Policies) Policy GG2: Making the best use of land 2.1 Chapter 1 is concerned with planning for good growth to improve the health and quality of life of all Londoners, and Policy GG2 is focussed on making the optimum use of land. In order to create high-density, mixed-use places that make the best use of land, the policy states that those involved in planning and development must (amongst other things) prioritise the development of Opportunity Areas (“OA”s), town centres, and sites which are well connected. In addition, they must proactively explore the potential to 1 Quod | Draft London Plan | BXC | March 2018 intensify the use of land to support additional homes and workspace and promote high density development, applying a design-led approach. 2.2 The DPs support the approach identified within Policy GG2 to making the best use of land. It is considered that directing high density development, as well as exploring the intensification of land uses, within well connected OAs and town centres is a welcome response to ensuring growth within London occurs in an appropriate manner. 3 Chapter 2 - Spatial Development Patterns Policy SD1: Opportunity Areas 3.1 Chapter 2 sets out the strategic framework for those parts of London that will see significant development over the lifetime of the Plan. The areas that will see the most significant change are identified as OAs and Policy SD1 sets out specific guidance for these areas. Part A seeks to ensure that OAs fully realise their growth and regeneration potential and Part B(4) recognises that larger OAs can define their own character and density. The DPs are supportive of both of these principles. 3.2 Indicative guideline figures are set out for housing and employment capacity in each of the OAs, and at Figure 2.8 Brent Cross/Cricklewood is identified as having potential for 9,500 new homes and 26,000 new jobs. The DPs welcome the continued commitment to allocating Brent Cross/Cricklewood as an OA, as well as these increased quantums for housing and employment capacity which recognise the need to optimise development in these areas. 3.3 The DPs however question why the strategic policy directions for OAs, previously contained in Annex 1 of the adopted London Plan, has not been carried through into the draft London Plan. The strategic policy direction provided clarity on the broad principles of each OA which assisted the effective implementation of the policy aspirations to maximise development potential and informed the preparation of OA Planning Frameworks. 3.4 The omission of the strategic policy direction means that there is less clarity on the intent of each OA, resulting in a less effective policy framework to facilitate sustainable growth. Policy SD7 – Town Centre Network 3.5 Policy SD7 is concerned with the town centre network and Table 1.1 sets out future potential changes to the town centre network. As with the earlier versions of the London Plan, Brent Cross is identified as a centre which has the potential to be re-classified as a Metropolitan Centre in the future. Paragraph 2.7.4 notes that “These centres are not recommended for immediate reclassification, however it is recognised that they may be appropriate for future reclassification, subject to strategic and Local Plan policies and conditional on matters such as capacity analysis, impact assessments, land use, public transport, walking and cycling, planning approvals and full implementation.” 3.6 The DPs support the recognition that Brent Cross should be given Metropolitan status. However, the context to the regeneration of BXC has changed since the previous London Plan was produced, to the point where development will commence imminently and as a result, Brent Cross should be re-classified as a Metropolitan town centre as part of the revised London Plan. 3.7 The BXC regeneration scheme has made significant progress with the planning permission now implemented and detailed design approved for Phase 1(A) North, which contains all key infrastructure including expansive highway and junction improvements. Detailed design for Phase 1B (North) has also 2 Quod | Draft London Plan | BXC | March 2018 been secured, which includes the transformation of Brent Cross Shopping Centre from an inward facing shopping centre to an outward facing network of streets and spaces, as well as a new high street which links to a pedestrian and cycle bridge over the A406, a new bus station and extensive public realm works. Pre-commencement conditions are now being prepared for discharge and early works are progressing on site ahead of main works beginning in Q1 2019. Argent Related, who are delivering the elements of the scheme south of the A406, has secured consent for the detailed design of Phase 1A (South) and Phase 1B (South), delivering over 300 residential homes. 3.8 Construction of the project will be well advanced by the time the London Plan has progressed through Examination in Public and has been adopted. In light of this, and alongside the continued recognition of the importance of the regeneration scheme within both strategic and local plan policy, Brent Cross in its regenerated form should be identified as a Metropolitan town centre. This re-classification will enable Barnet’s Local Plan to respond accordingly and develop a policy framework that will give the scheme the support it needs to fully realise its growth potential. 3.9 Table A1.1 provides further detail in respect of the roles of each town centre and Brent Cross is identified as an area with high commercial and residential growth potential and a centre which has the capacity, demand and viability to accommodate new and/or speculative office development. Brent Cross is also classified as a strategic area for regeneration. The DPs welcome the ongoing recognition of the town centre’s growth potential in respect of the identified development sectors which will assist enable its regeneration to come forward. 3.10 Notwithstanding this, we question why Brent Cross has not been allocated a night-time economy classification. The approved development scheme which will be coming forward imminently will comprise a mix of evening activities, including cultural, leisure, entertainment, food and drink, and shopping facilities. It is therefore considered that this should be recognised within the London Plan and a classification be applied accordingly to support the contribution that the development will have on the night-time economy within London. 3.11 It is noted that Figures A1.1 to A1.5 which support Table A1.1 are a useful addition but are difficult to navigate and should include labels so that specific centres can be easily recognised. Policy SD8 – Town centres: development principles and Development Plan Documents 3.12 Part A(1) of Policy SD8 considers that Development Plans and proposals should take a town centres first approach by: adopting a sequential approach to accommodating town centre uses such that new development of these uses is focused on sites within town centres or (if no sites are available, suitable or viable) on sites on the edges of centres that are, or can be, well integrated with the existing centre. 3.13 Part A(2) of the policy goes on to state this approach should be followed by: “firmly resisting out-of-centre development of town centre uses in line with the sequential approach in A(1) above, with limited exceptions for existing viable office locations in outer London (see Policy E1 Offices)” 3.14 Paragraph 24 of the NPPF deals with the location of town centre uses and states local planning authorities should require applications for main town centre uses to: “be located in town centres, then in edge of centre locations and only if suitable sites are not available should out of centre sites be considered.